Leveraging Technology for Growth

Written by

Technology is playing an increasingly central role in banks’ strategic plans. Now more than ever, banks rely on technology to deliver products and services, improve processes and the customer experience, acquire new customers and grow.

When it comes to new technology, banks essentially have four options: build it, license it, partner with a third party or buy it. Traditionally, only the largest banks had the resources and inclination to build technology in house; however, some smaller banks are now dedicating resources to developing technology themselves.

Much more commonly, banks obtain technology solutions from their core processors or other vendors. Over the last several years, there has been a proliferation of banks partnering with fintech companies to deploy their technology, or for banks to provide banking services to a customer-facing fintech company. As banks become more tech-centric, more are likely to explore acquiring fintech companies or fintech business lines. Each approach carries with it unique advantages, disadvantages, risks and legal and regulatory considerations.

The federal bank regulatory agencies have been especially active in recent years in the bank/fintech partnership space. In July 2021, the agencies published proposed updated interagency guidance on managing risks associated with third-party relationships, which includes guidance on relationships with fintech companies. Later in 2021, they released a guide intended to help community banks conduct appropriate due diligence and assess risks when considering relationships with fintech companies, and the Federal Reserve Board published a white paper on how community banks can access innovation by partnering with third-party fintech companies. Prior to that, the Federal Deposit Insurance Corp. published a guide intended for fintech companies interested in partnering with banks. These pronouncements indicate that while the agencies are generally supportive of banks innovating via fintech partnerships, their expectations for how banks conduct those relationships are increasing.

As technology and the business of banking become more intertwined, banks need to remain mindful not only of regulatory guidance on these partnerships specifically, but on the full spectrum of laws and regulations that are implicated — sometimes unintentionally — by these relationships. For example, partnership models that involve banks receiving deposits through a relationship with a fintech company could implicate the brokered deposit rules, which the FDIC updated in 2020 to account for how banks use technology to gather deposits.

As another example, partnership models that involve a fintech company offering new lending products funded by the bank, or the bank lending outside of its traditional market area, can raise fair lending and Community Reinvestment Act considerations, and potentially expose the bank to a heightened risk of regulatory enforcement action. Banks must keep in mind that when offering a banking product through a fintech partnership, regulators view that product as a product of the bank, which the bank must offer and oversee in accordance with applicable law and bank regulatory guidance.

What’s Next
Although bank/fintech partnerships have been around for some time, the amount of recent regulatory activity in this area suggests the agencies believe that many more of these partnerships, involving many more banks, will develop.

As the partnership model matures, more banks may become interested in developing closer ties with their fintech partner, including by investing cash in their fintech partner. Banks may be motivated to explore an investment to make its relationship with a fintech partner stickier, allow the bank to financially share in the fintech partner’s growth or enhance the bank’s attractiveness as a prospective partner to other fintech companies.

Banks considering investing in a fintech company or a venture capital fintech fund must understand not only the regulatory expectations associated with fintech partnerships generally, but also the legal authority under which the bank or its holding company would make and hold the investment.

As some banks start to look and operate more like technology companies, more may explore acquisitions of entire fintech companies or fintech business lines or assets. In addition to the many business and legal issues associated with any M&A transaction, banks considering such an acquisition have to be especially focused on due diligence of the target fintech company, integration of the target into the bank’s regulatory environment and ensuring that the target’s activities are permissible for the bank to engage in following the transaction.

Banks need innovative technology to succeed in today’s fiercely competitive financial services marketplace. Some will build it themselves, others will hire technology vendors or partner with fintech companies to deploy it and some will obtain it through acquisition. As banking and fintech evolve together, banks must understand and pay careful attention to the advantages and disadvantages, and legal and regulatory aspects, of each of these approaches.

7 Key Actions for Banks Partnering With Fintechs

Written by

A longer version of this article can be read at RSM US LLP.

Many banks are considering acquiring or partnering with existing fintechs to gain access to cutting-edge technologies and remain competitive in the crowded financial services marketplace.

There are many advantages to working with fintech partners to launch newer services and operations, but failing to properly select and manage partners or new acquisitions can have the opposite effect: additional risks, unforeseen exposures and unnecessary costs. Partnership opportunities may be a focus for leadership teams, given the significant growth and investments in the fintech space over the last decade. Consumer adoption is up: 88% of U.S. consumers used a fintech in 2021, up from 58% in 2020, according to Plaid’s 2021 annual report; conventional banks’ market share continues to drop.

Planning is everything when partnering with or acquiring a fintech company. Here are seven key actions and areas of consideration for banks looking for such partnerships.

1. Understand your customers on a deeper level: The first step before considering a fintech partner or acquisition is to understand what your consumers truly want and how they want those services delivered. Companies can pinpoint these needs via surveys, customer focus groups, call centers or discussions and information-gathering with employees.

Organizations should also explore the needs of individuals and entities outside their existing customer bases. Gathering data that helps them learn about their customers’ needs, lifestyle preferences and behaviors can help banks pinpoint the right technology and delivery channel for their situation.

2. Understand leading-edge technological advancements: While fintech partnerships can give a traditional bank access to new cutting-edge technologies, leaders still need to understand these technologies and the solutions. This might involve helping teams gain fluency in topics such as artificial intelligence that can improve credit decisioning, underwriting processes and fraud detection, automation that speeds up service delivery responses and customer onboarding, data analysis and state-of-the-art customer relationship management tools and more.

3. Prepare for culture shock: Fintechs, particularly those in start-up mode, will be used to operating at a different pace and with a different style than typical banks. Fintechs may behave more entrepreneurially, trying many experiments and failing often and fast. This entrepreneurial mindset has implications for how projects are organized, managed, measured, staffed and led.

4. Take a 360-degree view of risk: Fintechs may not have been subject to the same strict compliance as banks, but as soon as they enter a partnership, they must adhere to the same standards, regulations and controls. Any technology-led, third-party partnership comes with the potential for additional risks in areas such as cybersecurity, data privacy, anti-money laundering and myriad other regulatory compliance risks. Banks need to have a solid understanding of the viability and soundness of the fintech they might partner with, as well as the strength and agility of the leadership team. They should also ensure the new relationship has adequate business continuity and disaster recovery plans.

From vendor selections and background checks to mutual security parameters and decisions around where servers will be located, all potential exposures are important for banks to assess. A new fintech relationship could open new avenues for outside threats, information breaches and reputation damage.

5. Don’t underestimate the management lift needed:Acquiring or partnering with a fintech or third-party vendor involves significant management work to meet customer needs, keep implementation costs in line and merge technologies to ensure compatibility between the two organizations.

Employees at each company will likely have different approaches to innovation, which is one of the major benefits of teaming up with a fintech company; your organization can rapidly gain access to cutting-edge technologies and the overall agility of a startup. But management needs to ensure that this union doesn’t inadvertently create heartburn among employees on both sides.

6. Build ownership through clear accountability and responsibility: A fintech partnership requires management and oversight to be effective. Banks should consider the ownership and internal staffing requirements needed to achieve the full value of their investment with a fintech organization.

Don’t underestimate the time and effort needed to develop and deploy these plans. Based on the automation levels of the solution implemented, these resources may need dedicated time on an ongoing basis for the oversight and operations of the solution as well.

7. Stick to a plan:While in a hurry to launch a service, leadership teams may gloss over the whole steps of the plan and critical items may fall off. To combat this, banks should have a robust project plan that aligns with the overall innovation strategy and clear definitions around who is responsible for what. A vendor management program can help with this, along with strategic change management planning.

Balancing the demands of innovation with a thorough and thoughtful approach that considers customer behaviors, risks, resources and plans for new solutions will make fintech partnerships go as smooth as possible. Institutions would do well to incorporate these seven key areas throughout the process of a potential third-party partnership to ensure the maximum return on investment.

Regulatory Crackdown on Deposit Insurance Misrepresentation

Written by

Federal banking regulators have recently given clear warnings to banks and fintechs about customer disclosures and the significant risk of customer confusion when it comes to customers’ deposit insurance status.

On July 28, 2022, the Federal Deposit Insurance Corporation and the Federal Reserve issued a joint letter to the crypto brokerage firm Voyager Digital, demanding that it cease and desist from making false and misleading statements about Voyager’s deposit insurance status, in violation of the Federal Deposit Insurance Act, and demanded immediate corrective action.

The letter stated that Voyager made false and misleading statements online, including its website, mobile app and social media accounts. These statements said or suggested that: Voyager is FDIC-insured, customers who invested with the Voyager cryptocurrency platform would receive FDIC insurance coverage for all funds provided to, and held by, Voyager, and the FDIC would insure customers against the failure of Voyager itself.

Contemporaneously with the letter, the FDIC issued an advisory to insured depository institutions regarding deposit insurance and dealings with crypto companies. The advisory addressed the following concerns:

  1. Risk of consumer confusion or harm arising from crypto assets offered by, through or in connection with insured banks. This risk is elevated when a nonbank entity offers crypto assets to the nonbank’s customers, while offering an insured bank’s deposit products.
  2. Inaccurate representations about deposit insurance by nonbanks, including crypto companies, may confuse the nonbank’s customers and cause them to mistakenly believe they are protected against any type of loss.
  3. Customers can be confused about when FDIC insurance applies and what products are covered by FDIC insurance.
  4. Legal risk of insured banks if a crypto company or other third-party partner of the bank makes misrepresentations about the nature and scope of deposit insurance.
  5. Potential liquidity risks to insured banks if customers move funds due to misrepresentations and customer confusion.

The advisory also includes the following risk management and governance considerations for insured banks:

  1. Assess, manage and control risks arising from all third-party relationships, including those with crypto companies.
  2. Measure and control the risks to the insured bank, it should confirm and monitor that these crypto companies do not misrepresent the availability of deposit insurance and should take appropriate action to address any such misrepresentations.
  3. Communications on deposit insurance must be clear and conspicuous.
  4. Insured banks can reduce customer confusion and harm by reviewing and regularly monitoring the nonbank’s marketing material and related disclosures for accuracy and clarity.
  5. Insured banks should have appropriate risk management policies and procedures to ensure that any services provided by, or deposits received from, any third-party, including a crypto company, effectively manage risks and comply with all laws and regulations.
  6. The FDIC’s rules and regulations can apply to nonbanks, such as crypto companies.

At a time when crypto companies are increasingly criticized for courting perceived excessive risk and insufficient transparency in their business practices, the FDIC and other banking agencies are moving to ensure that these companies’ practices do not threaten the banking industry or its customers. On Aug. 19, the FDIC issued letters demanding that five crypto companies cease and desist from making false and misleading statements about their FDIC deposit insurance status and take immediate corrective action.

In addition to the FDIC’s suggestions in its advisory, we suggest both banks and fintech vendors consider the following measures to protect against regulatory criticism or enforcement:

  1. Banks should build the right to review and approve all communications to bank customers into their vendor contracts and joint venture agreements with fintechs and should revisit existing contracts to determine if any adjustments are needed.
  2. Banks should consult with legal counsel as to current and expected regulatory requirements and examination attitudes with respect to banking as a service arrangements.
  3. Fintechs should engage with experienced bank regulatory counsel about the risks inherent in their business and contractual arrangements with insured banks by which the services of the fintech is offered to bank customers.
  4. Banks should conduct appropriate diligence as to their fintech partners’ compliance framework and record.

Additionally, should a bank’s fintech partner go bankrupt, the bank should obtain clarity — to the extent that it’s unclear — as to whether funds on deposit at the bank are property of the bankruptcy estate or property of a non-debtor person or entity; in this case, the fintech’s customers. If funds on deposit are property of non-debtor parties, the bank should be prepared to address such party’s claims, including by obtaining bankruptcy court approval regarding the disposition of such funds on deposit. Additionally, the bank may have claims against the bankrupt fintech entity, including claims for indemnity, and should understand the priority and any setoff rights related to such claims.

Eyes Wide Open: Building Fintech Partnerships That Work

Written by

With rising cost of funds and increased operating costs exerting new pressures on banks’ mortgage, consumer and commercial lending businesses, management teams are sharpening their focus on low-cost funding and noninterest revenue streams. These include debit card interchange fees, treasury management services, banking as a service (BaaS) revenue sharing and fees for commercial depository services, such as wire transfers and automated clearinghouse (ACH) transactions. Often, however, the revenue streams of some businesses barely offset the associated costs. Most depository service fees, for example, typically are offered as a modest convenience fee rather than a source of profitability. Moreover, noninterest income can be subject to disruption.

Responding to both competitive pressures and signals of increased regulatory scrutiny, many banks are eliminating or further reducing overdraft and nonsufficient fund (NSF) fees, which in some cases make up a substantial portion of their fee income. While some banks offset the loss of NSF fees with higher monthly service charges or other account maintenance fees, others opt for more customer-friendly alternatives, such as optional overdraft protection using automatic transfers from a linked account.

In rethinking overdraft strategies, a more innovative response might be to replace punitive NSF fees with a more positive buy now, pay later (BNPL) program that allows qualified customers to make purchases that exceed their account balances, using a short-term extended payment option for a nominal fee.

Partnering with a fintech can provide a bank quick access to the technology it needs to implement such a strategy. It also can open up other potential revenue streams. Unfortunately, a deeper dive into the terms of a fintech relationship sometimes reveals that the bank’s reward is not always commensurate with the associated risks.

Risky Business
As the banking industry adapts to new economic and competitive pressures, a growing number of organizations are turning to bank-fintech partnerships and various BaaS offerings to help improve financial performance, access new markets, and offset diminishing returns from traditional deposit and lending activities. In many instances, however, these new relationships are not producing the financial results banks had hoped to achieve.

And as bank leaders develop a better understanding of the opportunities, risks, and nuances of fintech relationships, some discover they are not as well-prepared for the relationship as they thought. This is particularly true for BaaS platforms and targeted online service offerings, in which banks either install fintech-developed software and customer interfaces or allow fintech partners to interact directly with the bank’s customers.

Often, the fintech partner commands a large share of the income stream — or the bank might receive no share in the income at all — despite, as a chartered institution, bearing an inordinate share of the risks in terms of regulatory compliance, security, privacy, and transaction costs. Traditionally, banks have sought to offset this imbalance through earnings on the fintech-related account balances, overlooking the fact that deposits obtained through fintechs are not yet fully equivalent to a bank’s core deposits.

Moreover, when funds from fintech depository accounts appear on the balance sheet, the bank’s growing assets can put stress on its capital ratio. Unless the bank receives adequate income from the relationship, it could find it must raise additional capital, which is often an expensive undertaking.

Such risks do not mean fintech partnerships should be avoided. On the contrary, they can offer many benefits. But as existing fintech contracts come up for renewal and as banks consider future opportunities, they should enter such relationships cautiously, with an eye toward unexpected consequences.

Among other precautions, banks should be wary of exclusivity clauses. Most fintechs understandably want the option to work with multiple banks on various products. Banks should expect comparable rights and should not lock themselves into a one-way arrangement that limits their ability to work with other fintechs or market new services of their own. It also is wise to opt for shorter contract terms that allow the bank to re-evaluate and renegotiate terms early in the relationship. The contract also should clarify the rights each party has to customer relationships and accounts upon contractual termination.

Above all, management should confirm that the bank’s share of future revenue streams will be commensurate with the associated risks and costs to adequately offset the potential capital pressures the relationship might trigger.

The rewards of a fintech collaboration can be substantial, provided everyone enters the relationship with eyes wide open.

5 Considerations When Vetting Fintech Partnerships

Written by

Fintech collaborations are an increasingly critical component of a bank’s strategy.

So much so that Bank Director launched FinXTech, committed to bridging the gap between financial institutions and financial technology companies. Identifying and establishing the right partner enables banks to remain competitive among peers and non-bank competitors by allowing them to access modern and scalable solutions. With over 10,000 fintechs operating in the U.S. alone, finding and vetting the right solution can seem like an arduous task for banks.

The most successful partnerships are prioritized at the board and executive level. Ideally, each partnership has an owner — one that is senior enough to make decisions that dictate the direction of the partnership. With prioritization and owners in place, banks can consider fintech companies at all stages of maturity as potential partners. While early-stage companies inherently carry more risk, the trade-off often comes in the form of enhanced customization or pricing discounts. These earlier-stage partnerships may require the bank to be more involved during the implementation, compliance or regulatory processes, compared to working with a more-mature company.

There is no one-size-fits-all approach, and it’s important for banks to evaluate potential partners based on their own strategic plan and risk tolerance. When conducting diligence on fintechs of any stage or category, banks should place emphasis on the following aspects of a potential partner:

1. Analyze Business Health. This starts with understanding the fintech’s ability to scale while remaining in viable financial conditions. Banks should evaluate financial statements, internal key performance indicator reports, and information on sources of funding, including major investors.

Banks should also research the company’s competitive environment, strength of its client base and potential expansion plans. This information can help determine the fintech’s capability to sustain operations and satisfy any financial commitments, allowing for a long-term, prosperous partnership. This analysis is even more important in the current economic environment, where fresh capital may be harder to come by.

2. Determine Legal and Compliance. Banks need to assess a fintech’s compliance policies to determine if their partner will be able to comply with the bank’s own legal and regulatory standards. Executives should include quarterly and annual reports, litigation or enforcement action records, and other relevant public materials, such as patents or licenses, in this evaluation.

Banks may also want to consider reviewing the fintech’s relationship with other financial institutions, as well as the firm’s risk management controls and regulatory compliance processes in areas relevant to the operations. This can give bank executives greater insight into the fintech’s familiarity with the regulatory environment and ability to comply with important laws and regulations.

3. Evaluate Data Security. Banks must understand a fintech’s information and security framework and procedures, including how the company plans to leverage customer or other potentially sensitive, proprietary information.

Executives should review the fintech’s policies and procedures, information security control assessments, incident management and response policies, and information security and privacy awareness training materials. In addition, external reports, such as SOC 2 audits, can be key documents to aid in the assessment. This due diligence can help banks understand the fintech’s approach to data security, while upholding the regulator’s expectations.

4. Ask for References. When considering a potential fintech partnership, executives should consult with multiple references. References can provide the bank with insight into the company’s history, conflict resolution, strengths and weakness, renewal plans and more, allowing for a deeper understanding of the fintech’s past and current relationships. If possible, choose the reference you speak with, rather than allowing the fintech to choose.

5. Ensure Cultural Alignment. The fintech’s culture plays an important role in a partnership, which is why on-site visits to see the operations and team in action can help executives with their assessment. Have conversations with the founders about their goals and speak with other members of the team to get a better idea of who you will be working with. Partners should be confident in the people and technology — both will create a mutually successful and meaningful relationship.

Despite the best intentions, not all partnerships are successful. Common mistakes include lack of ownership and strategy, project fatigue, risk aversion and unreasonable expectations. Too often, banks are looking for a silver bullet, but meaningful outcomes take time. Setting expectations and continuing to re-evaluate the success and performance of these partnerships frequently will ensure that both parties are achieving optimal results.

Once banks establish partnerships, they must also nurture the relationship. Again, this is best accomplished by having a dedicated partner owner who is responsible for meeting objectives. As someone who analyzes hundreds of fintechs to determine quality, viability and partner value, I am encouraged by the vast number of technology solutions available to financial institutions today. Keeping a focused, analytical approach to partnering with fintechs will put your bank well on its way to implementing innovative new technology for all stakeholders.

Effective Oversight of Fintech Partnerships

Written by

For today’s banks, the shift to digital and embracing financial technology is no longer an option but a requirement in order to compete.

Fintechs enable banks to deploy, originate and service customers more effectively than traditional methods; now, many customers prefer these channels. But banks are often held back from jumping into fintech and digital spaces by what they view as insurmountable hurdles for their risk, compliance and operational teams. They see this shift as requiring multiple new hires and requiring extensive capital and technology resources. In reality, many smaller institutions are wading into these spaces methodically and effectively.

Bank oversight and management must be tailored to the specific products and services and related risks. These opportunities can range in sophistication from relatively simple referral programs between a bank and a fintech firm, which require far less oversight to banking as a service (often called BaaS) which requires extensive oversight.

A bank’s customized third-party oversight program, or TPO, is the cornerstone of a successful fintech partnership from a risk and compliance perspective, and should be accorded appropriate attention and commitment by leadership.

What qualifies as an existing best-in-class TPO program at a traditional community bank may not meet evolving regulatory expectations of a TPO that governs an institution offering core products and services through various fintech and digital partners. Most banks already have the hallmarks of a traditional TPO program, such as reviewing all associated compliance controls of their partner/vendor and monitoring the performance on a recurring basis. But for some banks with more exposure to fintech partners, their TPO need to address other risks prior to onboarding. Common unaccounted-for risks we see at banks embarking on more extensive fintech strategies include:

  • Reviewing and documenting partners’ money transmission processes to ensure they are not acting as unlicensed money transmitters.
  • Reviewing fintech deposit account’s set up procedures.
  • Assessing fintech partner marketing of services and/or products.
  • Ensuring that agreements provide for sufficient partner oversight to satisfy regulators.
  • Procedures to effectively perform required protocols that are required under the Bank Secrecy Act, anti-money laundering and Know Your Customer regulations, and capture information within the bank’s systems of record. If the bank relies on the fintech partner to do so, implementing the assessment and oversight process of the fintech’s program.
  • Assessing the compliance and credit risks associated with fintech partner underwriting criteria such as artificial intelligence, alternative data and machine learning.
  • Assessing the impact of the fintech strategy on the bank’s fair lending program and/or Community Reinvestment Act footprint.
  • The potential risk of unfair, deceptive or abusive acts or practices through the fintech partner’s activities.
  • True lender risks and documenting the institution’s understanding of the regulations surrounding the true lender doctrine.
  • Assessing customer risk profile changes resulting from the expansion of the bank’s services and or products and incorporating these changes into the compliance management system.
  • Revising your overall enterprise risk management program to account for the risks associated with any shift in products and services.

Finally, regulators expect this shift to more fintech partnerships to become the norm rather than the exception. They view it as an opportunity for banks to provide greater access to products and services to the underbanked, unbanked and credit invisible. Over the last couple of years, we have seen a number of resources deployed by bank regulators in this space, including:

  • Regulators creating various offices to address how banks can best utilize data and technology to meet consumer demands while maintaining safety, soundness, and consumer protection. The Federal Deposit Insurance Corp. has built FDITECH, the Office of the Comptroller of the Currency has an Office of Innovation, as does the Federal Reserve Board. The CFPB has aggregated their efforts to deploy sandboxes and issue “No-Action Letters” through its own Innovation Office.
  • The Federal Reserve issued a guide for community banks on conducting due diligence on financial technology firms in August 2021.
  • OCC Acting Comptroller Michael Hsu gave remarks at the Fintech Policy Summit 2021 in November 2021.
  • In November 2021, the OCC issued a release clarifying bank authority to engage in certain cryptocurrency activities, as well as the regulator’s authority to charter national trust banks.

Adopting best practices like the ones we listed above, as well as early communication with regulators, will place your bank in a great position to start successfully working with fintechs to expand and improve your bank’s products and services and compete in today’s market.

The Future of Banking

Written by

Open banking is bigger in the United States than it is in Europe, says Lee Wetherington, the senior director of corporate strategy for Jack Henry & Associates, one of the banking industry’s largest technology solution providers. For financial technology companies, that means an unlimited potential to access data, and offer products and services that customers would like or will like in the future.

Wetherington answers three questions in this video:

  • How can fintechs leverage open-banking rails to improve their offerings and reach?
  • What will the banking industry look like in 10 years?
  • Looking beyond 10 years, will there be a banking industry as we know it now?

Use Cases, Best Practices For Working With Fintechs

Written by

Bank leadership teams often come under pressure to quickly establish new fintech relationships in response to current market and competitive trends.

The rewards of these increasingly popular collaborations can be substantial, but so can the associated risks. To balance these risks and rewards, bank boards and senior executives should understand the typical use-case scenarios that make such collaborations appealing, as well as the critical success factors that make them work.

Like any partnership, a successful bank-fintech collaboration begins with recognizing that each partner has something the other needs. For fintechs, that “something” is generally access to payment rails and the broader financial system — and in some cases, direct funding and access to a bank’s customer base. For banks, such partnerships can make it possible to implement advanced technological capabilities that would be impractical or cost-prohibitive to develop internally.

At a high level, bank-fintech partnerships generally fall into two broad categories:

1. Customer-facing collaborations. Among the more common use cases in this category are new digital interfaces, such as banking-as-a-service platforms and targeted online offerings such as deposit services, lending or credit products, and personal and commercial financial management tools.

In some collaborations, banks install software developed by fintech to automate or otherwise enhance their interactions with customers. In others, banks allow fintech partners to interact directly with bank customers using their own brand to provide specialized services such as payment processing or peer-to-peer transactions. In all such relationships, banks must be alert to the heightened third-party risks — including reputational risk — that result when a fintech partner is perceived as an extension of the bank. The bank also maintains ultimate accountability for consumer protection, financial crimes compliance and other similar issues that could expose it to significant harm.

2. Infrastructure and operational collaborations. In these partnerships, banks work with fintechs to streamline internal processes, enhance regulatory monitoring or compliance systems, or develop other technical infrastructure to upgrade core platforms or support systems such as customer onboarding tools. In addition to improving operational efficiency and accuracy, such partnerships also can enable banks to expand their product offerings and improve the customer experience.

Although each situation is unique, successful bank-fintech partnerships generally share some important attributes, including:

  • Strategic and cultural alignment. Each organization enters the collaboration for its own reasons, but the partnership’s business plan must support both parties’ strategic objectives. It’s necessary that both parties have a compatible cultural fit and complementary views of how the collaboration will create value and produce positive customer outcomes. They must clearly define the roles and contributions and be willing to engage in significant transparency and data sharing on compatible technology platforms.
  • Operational capacity, resilience and compatibility. Both parties’ back-office systems must have sufficient capacity to handle the increased data capture and data processing demands they will face. Bank systems typically incorporate strict controls; fintech processes often are more flexible. This disparity can present additional risks to the bank, particularly in high-volume transactions. Common shortcomings include inadequate capacity to handle customer inquiries, disputes, error resolution and complaints. As a leading bank’s chief operating officer noted at a recent Bank Director FinXTech event, improper handling of Regulation E errors in a banking-as-a-service relationship is one of the quickest ways to put a bank’s charter at risk.
  • Integrated risk management and compliance. Although the chartered bank in a bank-fintech partnership inevitably carries the larger share of the regulatory compliance risk, both organizations should be deliberate in embedding risk management and compliance considerations into their new workflows and processes. A centralized governance, risk, and compliance platform can be of immense value in this effort. Banks should be particularly vigilant regarding information security, data privacy, consumer protection, financial crimes compliance and dispute or complaints management.

Proceed Cautiously
Banks should guard against rushing into bank-fintech relationships merely to pursue the newest trend or product offering. Rather, boards and senior executives should require that any relationship begins with a clear definition of the specific issues the partnership will address or the strategic objective it will achieve. In addition, as regulators outlined in recent guidance regarding bank and fintech partnerships, the proposed collaboration should be subject to the full range of due diligence controls that would apply to any third-party relationship.

Successful fintech collaborations can help banks expand their product offerings in support of long-term growth objectives and meet customers’ growing expectations for innovative and responsive new services.

5 Key Factors for Fintech Partnerships

Written by

As banks explore ways to expand their products and services, many are choosing to partner with fintech companies to enhance their offerings. These partnerships are valuable opportunities for a bank that otherwise would not have the resources to develop the technology or expertise in-house to meet customer demand.

However, banks need to be cautious when partnering with fintech companies — they are subcontracting critical services and functions to a third-party provider. They should “dig in” when assessing their fintech partners to reduce the regulatory, operational and reputational risk exposure to the bank. There are a few things banks should consider to ensure they are partnering with third party that is safe and reputable to provide downstream services to their customers.

1. Look for fintech companies that have strong expertise and experience in complying with applicable banking regulations.

  • Consider the banking regulations that apply to support the product the fintech offers, and ask the provider how they meet these compliance standards.
  • Ask about the fintech’s policies, procedures, training and internal control that satisfy any legal and regulatory requirements.
  • Ensure contract terms clearly define legal and compliance duties, particularly for reporting, data privacy, customer complaints and recordkeeping requirements.

2. Data and cybersecurity should be a top priority.

  • Assess your provider’s information security controls to ensure they meet the bank’s standards.
  • Review the fintech’s policies and procedures to evaluate their incident management and response practices, compliance with applicable privacy laws and regulations and training requirements for staff.

3. Engage with fintechs that have customer focus in mind — even when the bank maintains the direct interaction with its customers.

  • Look for systems and providers that make recommendations for required agreements and disclosures for application use.
  • Select firms that can provide white-labeled services, allowing bank customer to use the product directly.
  • Work with fintechs that are open to tailoring and enhancing the end-user customer experience to further the continuity of the bank/customer relationship.

4. Look for a fintech that employs strong technology professionals who can provide a smooth integration process that allows information to easily flow into the bank’s systems and processes.

  • Using a company that employs talented technology staff can save time and money when solving technology issues or developing operational efficiencies.

5. Make sure your fintech has reliable operations with minimal risk of disruption.

  • Review your provider’s business continuity and disaster recovery plans to make sure there are appropriate incident response measures.
  • Make sure the provider’s service level agreements meet the needs of your banking operations; if you are providing a 24-hour service, make sure your fintech also supports those same hours.
  • Require insurance coverage from your provider, so the bank is covered if a serious incident occurs.

Establishing a relationship with a fintech can provide a bank with a faster go-to-market strategy for new product offerings while delivering a customer experience that would be challenging for a bank to recreate. However, the responsibility of choosing a reputable tech firm should not be taken lightly. By taking some of these factors into consideration, banks can continue to follow sound banking practices while providing a great customer experience and demonstrating a commitment to innovation.